Droit Fiscal Américain

Tax Implications of Stock-Based Compensation, Transfer Pricing, and Cost-Sharing Arrangements

by: Olivier ThevozPublished on: 14/03/2026

Stock-based compensation is widely used to incentivize employees, but it raises complex tax and transfer pricing issues. This article analyzes the taxation of equity compensation, including stock options and RSUs, and examines the interaction between IRC §§83, 482, and 4501 in multinational structures.

US Tax
Tax Implications of Stock-Based Compensation, Transfer Pricing, and Cost-Sharing Arrangements